The Collection and Use of Personal Information
The following list describes the limited categories of Personal Information we may have collected about you in the past 12 months. As described above, we collect these categories of Personal Information from you directly, automatically from your interactions with us, or from third party sources. We collect this Personal Information for the business and commercial purposes of providing our services to you or otherwise for the management and administration of our website and business, to evaluate your job application or for purposes of your employment, communicating with you about our products and services, for fraud detection and prevention and other security purposes, to comply with legal requirements, enforce our policies or contracts, or otherwise to protect our rights and interests.
Identifiers, such as name, email address, address, phone number, facsimile number, IP address, social security number or other similar identifiers.
Characteristics of protected classes and demographic information, such as age, sex, and marital status. Note that we do not collect this information from job applicants.
Commercial and financial information, such as records of personal property, products or services purchased, obtained, or considered, information on investments, assets, net worth, tax status, holdings, account balances, transaction history, bank account details, wire transfer instructions.
Internet or other electronic activity information, including information regarding an individual’s interaction with a website or mobile application, emails sent and received.
Audio, electronic, visual, thermal, or olfactory information, such as copies of drivers’ license, passport or other photograph identification, or information from security cameras in certain of our facilities that deploy them.
Professional or employment-related information Education information
Inferences drawn from any of the information identified above, to create a profile reflecting an investor’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Information Collected and Stored Automatically
The Site automatically collects some technical information from you when you visit the Site in order to give you the best possible experience. The Site uses web measurement technology (e.g., Google Analytics) to automatically track how visitors interact with the Site, including where they came from, what they did on the Site and whether they completed any pre-determined tasks while on the Site. Aggregate data is used to help improve our user interface and diversify our content offerings to meet the needs of our customers, track operational problems, prevent fraud, and improve the effectiveness, security, and integrity of the Site. This information is retained in accordance with the CAIS data retention policy. For each page that you visit, we collect and store information about your interactions with our site, including the following technical information:
Date and time of access
URL address of the Site webpage visited
Internet domain and IP address from which our website was accessed
Type of browser and operating system used to access the Site (if provided by the browser)
URL address of the referring page (if provided by the browser)
Completion or success status of the request for a webpage or other on-line item
File size of the webpage visited
This information is used to help us make the Site more useful for you. With this data we learn about the number of visitors to our Site and the types of technology our visitors use. In the password protected portion of the Site, CAIS maintains the right to track and store all actions which are performed during each visit; this is subject but not limited to products that were viewed and documents accessed; other than our third party service providers that support our site processes, we do not share this data with anyone outside CAIS unless necessary for law enforcement purposes or to otherwise comply with applicable law or to protect our rights and property and enforce our terms.
Information That You Provide Voluntarily
Cookies and other Tracking Technologies
We use two types of cookies. A session cookie is a line of text that is stored temporarily in your web browser’s memory cache and will expire when the browser is closed. A session cookie is not placed on any hard drive, and it is destroyed as soon as you close your browser. We may use session cookies to facilitate certain site functionality and features. A persistent cookie is saved to a file on your hard drive and is accessed whenever you re-visit the website that put it there. This lets that website remember what you were interested in the last time you visited. We use persistent cookies to enable analytics (e.g., Google Analytics) to differentiate between new and returning Site visitors. Persistent cookies remain on your computer between visits to the Site until they expire.
CAIS may utilize third party services to enhance its distribution of data and information (e.g., videos) through links from the Site. A persistent cookie may be set by such a third-party provider when you click on the provider’s link in order to access CAIS data (e.g., play a video).
By default, persistent cookies and web measurement technologies are automatically used when you visit the Site. We may allow third party ad serving companies or ad networks to display third party advertisements on the Site. Some of these companies may place a persistent cookie in order to recognize your computer each time they send you an online advertisement. Thus, these companies may compile information about where you are using your computer, where you saw their advertisements, and which ads you clicked on. This information allows these companies to deliver targeted advertisements that they believe will be of most interest to you. We do not have access to the cookies that may be placed by these companies. If you are interested in learning more about and/or opting out of online advertising, we encourage you to visit one of the advertising industry-developed opt-out pages, such as www.youradchoices.com or aboutads.info. Please note that our site does not respond to browser “Do Not Track” signals.
Sharing of Information
CAIS does not sell your Personal Information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share Personal Information with certain third parties without notice to you, including those set forth below. For each of the personal information categories listed above, we may share this information with other entities and affiliates for business or commercial purposes.
Agents, Consultants and Related Third Parties:
We, like many businesses, sometimes hire other companies to perform certain business-related functions. Examples include mailing information, maintaining databases, hosting services and processing payments. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function. We require such third parties to maintain the confidentiality of such information and use such information only as necessary to provide us with designated services. We may also share information with our affiliates that assist us in the management and administration of our business.
We may aggregate your Personal Information with Personal Information of other users of the Site and disclose such information in a non-personally identifiable manner to advertisers and other third parties for marketing and promotional purposes. In these situations, we will not disclose to these entities any information that could be used to identify you or your clients personally.
We may disclose Personal Information if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) at the request of governmental authorities or other third parties conducting an investigation (c) to detect and protect against fraud, or any technical or security vulnerabilities, (d) to respond to an emergency, (e) act in urgent circumstances to protect the personal safety of users of the Site or the public, (f) protect against legal liability, (g) or otherwise to protect the rights, property, safety, or security of our business, third parties, visitors to our websites, or the public.
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets
CAIS may also use online survey instruments to obtain feedback on your experience with the Site. The survey initiation pops up for a random sample of visitors, is voluntary and does not collect personal information. If you decline the survey, you will still have access to the same information and resources of the Site as those who do take the survey. The survey reports are available only to the Site’s managers and other staff who require this information to perform their duties. CAIS retains the data from the survey results in accordance with its data retention policy.
Social Media and Third-Party Websites
CAIS uses some social media tools and websites to interact with its customers and resource partners. Social media websites are used to publicize CAIS programs and services and engage with members of the public. CAIS does not use third party websites to solicit and collect personal information from individuals. Any personal information collected by a third-party website will not be transmitted to CAIS unless required for law enforcement purposes or as otherwise permitted by law. CAIS’ privacy and other web policies do not apply to these third-party sites and we encourage you to read the policies of the third-party site when deciding whether to use it.
Site Security and Safeguarding of Information
CAIS maintains reasonable administrative, technical, and physical policies, procedures and safeguards designed to assist us in protecting the Personal Information we collect against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. These measures include computer safeguards, secured files and buildings, and employee background checks. For Site security purposes and to ensure that this service remains available to all users, this computer system employs commercial software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage. The CAIS computer system is protected by firewall and anti-virus software and employs encryption technology for data storage. CAIS networks also employ automated network and server monitoring. All major components of the application and hardware architecture have been designed for automatic or semi-automatic rollover in the event of a failure. We take commercially reasonable steps to protect Personal Information and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from the Site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Information to us or to any other party via the Internet or e-mail.
Other Terms and Conditions
We are also committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests, please contact us at (212) 300-9350 or contact [email protected].
Questions or comments regarding the Site, including any reports of non-functioning links, please contact us.
Capital Integration Systems LLC & CAIS Capital LLC (collectively “CAIS”) – California Consumer Privacy Act (CCPA) Notification
CAIS provides an alternative investment platform (the “CAIS Platform”) and other related services exclusively to eligible registered investment advisory firms, broker-dealers, a limited number of institutional family offices, banks and trusts (“Platform Clients”). CAIS takes reasonable steps to ensure Platform Clients meet the threshold requirements of an “institutional account”, as defined by FINRA Rule 4512(c). CAIS operates in a business-to-business context, and as a service provider to other companies, and it is subject to the Gramm-Leach-Bliley Act (“GLBA”).
Information CAIS Collects CAIS collects “Personal Information” in order to provide its Platform Clients with products and services, or satisfy certain legal and regulatory obligations. Pursuant to the CCPA, “Personal Information” is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. Categories and examples of “Personal Information” that CAIS has collected in the past twelve (12) months includes:
Identifiers: This may include First Name, Last Name, Email Address, IP Address, Telephone Number, Username, Name of Employer, Physical Address of Employer.
Commercial Information: This may include records of products and transactions made through the CAIS Platform; records of products considered, consuming histories or details related to interests and activities made on the CAIS Platform.
Professional Information: This may include employer information, job history, regulatory history, and other CAIS Platform due diligence required by regulation, as well as industry best practice standards.
Geolocation Data: Your IP Address.
Cookie Data/ Internet Activity: This pertains to internet information concerning interactions with the CAIS public facing website, and the CAIS Platform.
Sources of Information CAIS collects “personal information” directly from CAIS Platform Users. For example, “personal information” can be obtained by corresponding with CAIS, when a user interfaces with products on the CAIS Platform, and when a user completes a CAIS Platform profile. CAIS may also collect “personal information” through subscription documentation and other securities business-related agreements.
CAIS also collects “personal information” indirectly by capturing user activities on the CAIS Platform. CAIS also collects “personal information” through employers, by way of onboarding the employing entity as a CAIS Platform user. CAIS may also collect “personal information through various third-party vendors, consistent with CAIS’s due diligence practices, and compliance and regulatory responsibilities. This information may be received in writing, in person, telephonically, or electronically.
Use of Personal Information California residents should be advised that “personal information” collected by CAIS is used in the normal course of business to deliver financial and technology services to Platform Clients, to seek to provide an optimal client service experience to its Platform Clients, as well as to comply with certain legal and regulatory requirements. CAIS may also use “personal information” collected in circumstances where we have received authorized consent.
More specifically, CAIS also uses “personal information”, such as “Identifiers” and “Commercial Information” (described in the “Information CAIS Collects” section above) to communicate with Platform Clients about products and services and to manage relationships with Platform Clients. CAIS uses “personal information” to send communications such as e-newsletters, information on certain events, and our services. CAIS also uses “personal information”, like “Identifiers” and “Commercial Information” to assist a Platform Client with the facilitation of an investment made through the CAIS Platform. CAIS may use “personal information” to support, personalize or develop the services made available to Platform Clients.
Selling/Sharing of Personal Information CAIS does not sell “personal information” to third parties. CAIS has no knowledge of selling or sharing “personal information” of consumers under 16 years of age.
CAIS may share “personal information” in the normal course of business. As part of its delivery of financial and technology services, CAIS may share “personal information”, such as “Commercial Information” (described in the “Information CAIS Collects” section above) with certain third-party organizations that are providing a financial service or product to CAIS Platform Users, or in connection with the facilitation of an investment made through the CAIS Platform. CAIS may also share “personal information”, such as “Identifiers” and “Commercial Information” with other third-party service providers, such as fund administrators, compliance vendors, fund accountants, external auditors, asset managers.
Disclosure of Personal Information CAIS may disclose “personal information” where and if required by law or regulation, such as with the Financial Industry Regulatory Authority (FINRA), the United States Securities and Exchange Commission, or other applicable regulatory authority. CAIS may also disclose personal information with a third party when such disclosure is deemed necessary to protect or defend CAIS’s legal or business interests.
Notice of Rights California residents have certain data privacy rights with respect to “Personal Information”, as defined in the CCPA. These rights are:
Right to Know: the right to know what personal information CAIS has collected, including categories of personal information, categories of sources from which the personal information is collected, the business or commercial purposes for collecting, selling, or sharing personal information, the categories of third parties to whom CAIS discloses personal information, and the specific pieces of personal information that CAIS has collected about the consumer.
Right to Delete: the right to delete personal information that CAIS has collected from the consumer, subject to certain exceptions.
Right to Correct: the right to correct inaccurate personal information that CAIS maintains about a consumer.
Right to Opt Out: the right to opt out of the sale personal information. As noted earlier, CAIS does not sell personal information to another business or to a third-party for monetary or other valuable considerations, as defined in the CCPA.
Right to Limit Use: the right to limit the use of personal information.
Right to Non-Discrimination: the right to not receive discriminatory treatment for exercising data privacy rights under the CCPA.
Request to Exercise Your Rights It is important to emphasize that California residents have the right to opt out of the sale of their “personal information”. As noted earlier, CAIS does not sell “personal information” to third parties for monetary or other valuable consideration, as defined in the CCPA.
To exercise your CCPA rights, including your Right to Opt Out, please email us at [email protected], or contact us at (212) 300-9350. CAIS will not discriminate against you for exercising your rights. In certain circumstances, before responding to your request, we will need to verify identity based on information we maintain about you. The specific verification data we may request will vary depending on your relationship with us and the nature of your request. You may place a request through an authorized agent; however, you will also need to verify the agency request as well. Requests that relate to a household must be placed through a verified request from each member of the household. For any request, if we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
Capital Integration Systems LLC – General Data Protection Regulation (GDPR) Privacy Notice
Capital Integration Systems LLC (“CAIS”, the “Firm”) and its affiliated entities provide certain financial and technology services to eligible registered investment advisory firms, broker-dealers, a limited number of institutional family offices, and banks and trusts located in the United States. CAIS and its affiliated entities generally do not provide financial and technology services to similarly situated financial institutions located in the United Kingdom (UK) and the European Union. CAIS maintains an affiliated UK entity, which provides technology services exclusively to the Firm and its affiliated entities domiciled in the United States. This privacy notice applies to data subjects, as defined by GDPR.
What Data Might We Collect? CAIS collects the following data:
Personal Identification Information: This may include First Name, Last Name, Email Address, Telephone Number.
Professional Information: This may include employment information, job history, and other due diligence information required by way of law, regulation or best practice standards.
Geolocation Data: Your IP Address.
Cookie Data/Internet Activity: This pertains to information concerning interactions with the CAIS public facing website.
When Might We Collect Data?
When a data subject located in UK or EU applies for employment at CAIS
When a data subject located in UK or EU accesses or views the CAIS public facing website
How Will We Use Your Data?
To evaluate an application for employment
To monitor traffic and activity on the CAIS public facing website
How Will We Share Personal Information?
CAIS will not sell your personal information to third parties.
CAIS will not generally share your personal information without your agreement
Data Protection Rights CAIS is required to make sure you are fully aware of your data protection rights. If you are a data subject in the UK or EU and you provide personal information to CAIS, you are entitled to the following:
The Right to Access: You have the right to request CAIS for copies of your personal data. Please note that CAIS may charge a fee for this service.
The Right to Rectification: You have the right to request that CAIS correct any information you believe is inaccurate. You also have the right to request that CAIS complete information you believe to be incomplete.
The Right to Erasure: You have the right to request that CAIS erase your personal data, subject to certain conditions, statutory limits, and prerequisites.
The Right to Restrict Processing: You have the right to request that CAIS restrict the processing of your personal data, which means that the Firm suspends the processing of your personal information for a certain period. This may happen when the accuracy of your personal information is contested but CAIS requires time to verify the accuracy/inaccuracy, or if your personal data has been unlawfully processed and you request restriction of processing instead of deletion.
The Right to Data Portability: You have the right to request that CAIS transfer the data that we have collected to another organization, or directly to you, under certain conditions.
To exercise your rights, please email us at [email protected], or contact us at +1-212-300-9350. To the extent permitted by law, we will need to verify your identity, or the identity of your agent, and ensure the authenticity if your request.
Data Processing If you are a data subject located in the UK or EU and you provide personal information directly, CAIS will process your information in accordance with the following requirements:
Consent: Processing will be based on your consent (e.g., you voluntarily contact us).
Legitimate Interests: Processing is necessary for the Firm’s legitimate interests (e.g., monitoring the use of the CAIS public facing website).
Contract Undertaking: Processing is necessary for the performance of a contract to which you are a party.
Legal Compliance: Processing is required to comply with a legal or statutory obligation.
If you are a data subject in the UK or EU, please know that you are entitled to file a complaint with your data protection authority. For the data protection authority in the UK, please visit https://ico.org.uk/ and navigate to the “Make a Compliant” icon. For data protection authorities located in the EU, please visit https://edps.europa.eu/data-protection/our-role-supervisor/complaints_en.